OREANDA-NEWS. August 23, 2016. United States Environmental Protection Agency (EPA) issued “Consideration of Greener Cleanup Activities in the Superfund Cleanup Process” in the form of a guidance memorandum to Regional Superfund National Program Managers and Regional Counsels.

So what does it mean to site owners?

The memorandum recommends approaches for regional remedial Superfund programs to consider when evaluating greener cleanup activities throughout the remedy selection process, including during response action selection and implementation. However, the guidance memorandum leaves implementation of the guidance to the regions and does not amend or modify the National Contingency Plan. Implementation of greener cleanup activities is not a regulatory requirement and only applies on a voluntary basis.

The guidance is notable in that it ties together a number of themes previously published by EPA along with some new guidance areas, including:

  • Identifying where greener cleanup activities fit into the CERCLA decision making process
  • A preference for using EPA’s Spreadsheets for Environmental Footprint Analysis (SEFA) tool for footprint analysis assessments
  • Citation of background and legal authority
  • Selecting and documenting greener cleanup activities in decision documents, including discussion of how greener cleanup activities will reduce the environmental footprint
  • Enforcement mechanisms when incorporating greener cleanup activities into the response action

EPA intends for this guidance to be used for both Superfund-lead sites and Potentially Responsible Parties lead sites.

The guidance provides recommended approaches for implementing greener cleanup activities throughout the CERCLA process and specifically mentions:

  • Conducting a best practices or footprint analysis
  • Incorporation into site characterization
  • Evaluating and incorporating greener cleanup activities in the Remedial Investigation/Feasibility Study or Engineering Evaluation/Cost Analysis
  • Selecting and documenting greener cleanup activities in decision documents

The guidance memorandum closes with a recommendation that regions consider and, as appropriate, incorporate greener cleanup activities into the response decision-making and implementation processes.

Attachment 1 of the guidance memorandum provides examples of CERCLA greener cleanup activities and ways to reduce environmental footprints, specifically:

  • Use best practices resources
  • Use an environmental footprint calculator
  • Consider potential land uses such as greenways and pollinator habitats, as appropriate
  • Implement responses in a more energy-efficient manner
  • Use cleaner and more energy-efficient equipment and construction techniques
  • Use sustainable materials
  • Generate renewable energy onsite
  • Purchase renewable energy

Attachment 2 of the guidance memorandum provides information on how greener cleanup considerations can be considered in the CERCLA feasibility study evaluation criteria, with the most appropriate place being the assessment of environmental impacts under the criterion of short-term effectiveness.

CH2M has a methodology for implementing all of the elements of EPA’s guidance. For more information, please contact Paul Favara.